UNITED STATES DISTRICT COURT
                  FOR THE EASTERN DISTRICT OF PENNSYLVANIA

                    UNITED STATES OF AMERICA, Plaintiff,
                                     v.
          ROBERT L. D'ANJOLELL MEMORIAL HOME, P.C., a corporation,
      ROBERT L. D'ANJOLELL, SR., individually and as an officer of the
                                corporation,
   ANTHONY ROMANO, individually and as an officer of the corporation, and
      ROBERT L. D'ANJOLELL, JR., individually and as an officer of the
                          corporation, Defendants.
                              Civil Action No.

                       COMPLAINT FOR CIVIL PENALTIES
                      AND INJUNCTIVE AND OTHER RELIEF

   Plaintiff, the United States of America, acting upon notification and
   authorization to the Attorney General by the Federal Trade Commission
   ("Commission"), for its complaint alleges that:

   1. Plaintiff brings this action under Sections 5(a)(1), 5(m)(1)(A), 9,
   13(b) and 16(a) of the Federal Trade Commission Act ("FTC Act"), 15
   U.S.C. §§ 45(a)(1), 45(m)(1)(A), 49, 53(b) and 56(a), to obtain
   monetary civil penalties and injunctive and other relief for
   defendants' violations of the Commission's Trade Regulation Rule
   Concerning Funeral Industry Practices ("Rule" or "Funeral Rule"), 16
   C.F.R. Part 453.

                          JURISDICTION AND VENUE

   2. This court has jurisdiction over this matter under 28 U.S.C.
   1331, 1337(a), 1345, and 1355 and under 15 U.S.C. §§ 45(m)(1)(A), 49,
   53(b) and 56(a). This action arises under 15 U.S.C. § 45(a)(1).

   3. Venue in the Eastern District of Pennsylvania is proper under 15
   U.S.C. § 53(b) and under 28 U.S.C. §§ 1391(b-c) and 1395(a).

                                DEFENDANTS

   4. Defendant Robert L. D'Anjolell Memorial Home, P.C. is a
   Pennsylvania corporation with its office and principal place of
   business located within the Eastern District of Pennsylvania at 2811
   West Chester Pike, Broomall, Pennsylvania 19008. Robert L. D'Anjolell
   Memorial Home, P.C. transacts business in this district.

   5. Defendant Robert L. D'Anjolell, Sr. is the President of Defendant
   Robert L. D'Anjolell Memorial Home, P.C. He resides at 717 South
   Warren Avenue, Malvern, Pennsylvania 19355. His business address is

                        UNITED STATES DISTRICT COURT
                  FOR THE EASTERN DISTRICT OF PENNSYLVANIA

                   UNITED STATES OF AMERICA, Plaintiff,

                                     v.

          ROBERT L. D'ANJOLELL MEMORIAL HOME, P.C., a corporation,
      ROBERT L. D'ANJOLELL, SR., individually and as an officer of the
                                corporation,
   ANTHONY ROMANO, individually and as an officer of the corporation, and
      ROBERT L. D'ANJOLELL, JR., individually and as an officer of the
                          corporation, Defendants.

                              Civil Action No.

                               CONSENT DECREE

   WHEREAS: Plaintiff, the United States of America, has commenced this
   action by filing the Complaint herein; defendants have waived service
   of the Summons and Complaint; the parties have been represented by the
   attorneys whose names appear hereafter; and the parties have agreed to
   settlement of this action upon the following terms and conditions,
   without adjudication of any issue of fact or law and without
   defendants admitting liability for any of the matters charged in the
   Complaint;

   THEREFORE, on the joint motion of the plaintiff and defendants, it is
   hereby ORDERED, ADJUDGED, and DECREED as follows:

   1. This Court has jurisdiction of the subject matter and of the
   parties.

   2. The Complaint states a claim upon which relief may be granted
   against the defendants under Sections 5(a)(1), 5(m)(1)(A), 9, 13(b),
   and 16(a) of the Federal Trade Commission Act, 15 U.S.C. §§ 45(a)(1),
   45(m)(1)(A), 49, 53(b), and 56(a).

                               CIVIL PENALTY

   3. Defendants, Robert L. D'Anjolell Memorial Home P.C., Robert L.
   D'Anjolell, Sr., Anthony Romano, and Robert L. D'Anjolell, Jr., and
   their successors and assigns, shall pay to plaintiff a civil penalty,
   pursuant to Section 5(m)(1)(A) of the Federal Trade Commission Act,
   15 U.S.C. § 45(m)(1)(A), in the amount of Eleven-Thousand-Dollars
   ($11,000). Defendants are jointly and severally responsible for paying
   the penalty.